Marius Cristian Brînzea · Managing Partner
16 September 20265 min read
The EUDR prohibits placing on the Union market (and exporting from the Union) products obtained from land that was deforested or degraded after 31 December 2020. The regulation covers seven commodities - cattle, cocoa, coffee, palm oil, rubber, soya and wood - plus a long list of derived products, identified by CN codes in Annex I.
For companies in Romania, this means far more than forestry operations: the importer of green or roasted coffee, the chocolate manufacturer, the tyre distributor, the furniture factory that brings in boards from outside the EU - all of them are in scope. The December 2025 revision brought one notable exception: printed products under CN chapter 49 (books, newspapers) were removed; paper and cardboard remain.
The central mechanism is due diligence: you collect information on origin - including the geolocation of the plots where the commodity was produced -, you assess the risk of deforestation and illegality, and if the risk is not negligible, you mitigate it. Before placing the product on the market, the operator submits a due diligence statement (DDS) in the EU information system and receives a reference number that accompanies the goods downstream.
The revision has noticeably simplified the administrative side: the full DDS is submitted only by the first operator placing the product on the EU market; downstream, the obligation is to collect and keep the reference numbers from your suppliers for five years. For sourcing exclusively from countries classified as low risk, simplified due diligence applies, with no full risk assessment. The penalties, however, have not been relaxed: the maximum fine provided for by Member States must be at least 4% of the annual turnover generated in the EU.
From 30 December 2026, the regulation applies to large and medium-sized operators and traders; micro and small enterprises (established by 31 December 2024) have until 30 June 2027, under a much simplified regime. The EU information system is open - accounts can be created and tested now.
Where do you start? An inventory of your products by CN code, checked against Annex I; then establishing your role on each flow - operator or trader, large or small - because your role determines what you submit and what you merely keep; then the requests to suppliers for geolocation and reference numbers. The Circulad'OR team can run this portfolio screening and build the due diligence procedure together with you - write to us while there is still time to prepare, not to rush.
The first conversation is free: you find out what applies to you, by when, and who does it - you, us, or the application.